Yesterday,
the Centers for Medicare & Medicaid Services (CMS) issued a proposed
rule updating the requirements of the quality payment program (QPP)
for physicians and eligible clinicians mandated by the Medicare Access and CHIP
Reauthorization Act of 2015. The QPP includes two tracks – the default
Merit-based Incentive Payment System and advanced alternative payment models.
The rule proposes key policies for the QPP's 2018 performance period, which
will affect clinician payment in 2020. Among other policies, CMS proposes to
increase the MIPS's low-volume threshold, thereby excluding more than 585,000
eligible clinicians from the program. CMS also proposes to implement a MIPS
reporting option that allows hospital-based clinicians to use their hospital's
value-based purchasing measure results in the MIPS program. CMS also proposes to
continue using a 90-day reporting period for the advancing care information
category in 2018, and to allow clinicians to use the 2014 edition of certified
electronic health records for the ACI category. In addition, CMS proposes
policies related to clinicians' ability to earn incentives for participation in
advanced APMs. This includes more detail regarding the all-payer option that,
beginning in 2019, will allow clinicians to qualify for advanced APM incentives
based on combined participation in alternative payment arrangements with
Medicare and non-Medicare payers (including Medicare Advantage, Medicaid and
private payers).